Supreme Court Wary of Altering District Court Review Doctrine

The US Supreme Court appeared unlikely to lay out new boundaries for an obscure legal doctrine that says federal district courts lack the authority to consider lawsuits seeking to invalidate judgments by state courts.

The justices for the most part seemed skeptical at arguments on Monday that the doctrine shouldn’t apply to litigants whose case is still going through appeals in the separate state courts’ system.

A lot of their concerns boiled down to what makes sense for both federal and state interests, as well as what incentives such a rule would create in litigation.

“I’m sorry, tell me what the value is to having a federal district court and a state appellate court simultaneously reviewing a state court judgment,” Justice Sonia Sotomayor said. “What’s the value in that?”

The so-called Rooker-Feldman doctrine, which gets its name from a pair of Supreme Court cases from the last century, is designed to prevent losers of state court judgments from looking to a federal trial court to void such a decision.

But a Maryland native who claims she entered into a consent order with a state hospital under duress claimed there’s no statutory basis to bar her from trying to vindicate her claims in federal court amid her state appeal.

Arguing on her behalf, Cooley partner Elizabeth Prelogar, the Biden-era solicitor general, said during arguments that the doctrine has always been intended to be limited to final state court judgments, and that the justices should consider eliminating the standard altogether if it were to apply in this case.

That sparked pushback from her counterpart, Lisa Blatt, the Williams & Connolly partner representing the University of Maryland Medical System Corp.

The rule Prelogar promoted is “backwards,” Blatt said, and doesn’t consider the potential real-world costs of litigants trying to short-circuit state processes in lawsuits targeting medical systems.

“You have to go find a lawyer to go, like, defend in a lot of suits,” she said. “It’s not like money grows on trees for hospitals.”

State v. Federal

The back-and-forth came in a protracted dispute tied to a 35–year-old Maryland resident’s claims that a medical center in the state committed her for treatment against her will.

The petitioner, identified as T.M., has a rare medical condition in which ingesting foods containing gluten can lead to episodes of psychosis. She experienced such an episode in 2023 after consuming gluten and was taken to the Baltimore Washington Medical Center where she sought to be admitted voluntarily.

But that request was denied, according to her submissions to the court, and she was confined at the facility for nearly three months, where she alleges she was involuntarily injected with antipsychotic medications.

T.M. and her father filed suits in state court, including a habeas petition seeking her release, as well as a federal lawsuit claiming her constitutional rights were violated.

The medical center ultimately agreed to release her under certain conditions, including that she’d drop all of her pending lawsuits, and a Maryland state court entered it as a consent order.

T.M. and her parents ultimately challenged that order to a state appeals court. Along with taking that step, they brought another lawsuit in federal court seeking an injunction blocking enforcement of the order and declaring that she agreed to it under duress.

Both a Maryland district court and the US Court of Appeals for the Fourth Circuit, however, found the Rooker-Feldman doctrine required them to dismiss the case.

While T.M.'s lawyer, Prelogar, faced tough questioning, some of the justices were open to the arguments that the Rooker-Feldman doctrine has expanded beyond its limits and proven to be a source of confusion for lower courts.

Justice Neil Gorsuch appeared open especially to the argument that other principles like preemption would resolve many of the issues that could arise over state and federal jurisdiction.

Justice Elena Kagan also noted that a primary rationale for the doctrine has always been confined to an interpretation of statutory text on jurisdiction that would favor the petitioner’s view. Questioning Blatt, she cautioned that deciding her way “sends a broader message about what the Rooker-Feldman doctrine is about.”

‘Not Dobbs’

While the justices are not asked to decide the viability of the doctrine, Prelogar pushed for tossing it should it extend in this case. That prompted some notable exchanges between the justices, such as when Jackson expressed confusion on why she raised it.

Prelogar used that as opening to cite the court’s decision in 2022 overruling Roe v. Wade and eliminating the legal right to abortion.

Blatt, in response, said: “This is not Dobbs, this is not Roe v. Wade.”

“You’re not going to overrule,” she added. “Sorry, I don’t think you’re going to do it. Not in an April case.”

The case is T.M. V. University of Maryland Medical System Corp., U.S., 25-197, 4/20/26